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THINK BIGGER DO GOOD<br />

POLICY SERIES<br />

<strong>Redesigning</strong> <strong>Federal</strong><br />

<strong>Health</strong> <strong>Insurance</strong><br />

<strong>Policies</strong> <strong>to</strong> <strong>Promote</strong><br />

<strong>Children’s</strong> <strong>Mental</strong><br />

<strong>Health</strong><br />

Kimberly Hoagwood, Ph.D.<br />

Cathy and Stephen Graham Professor and Vice Chair for Research,<br />

New York University & Vice Chair for Research, Department of<br />

Child and Adolescent Psychiatry, NYU School of<br />

Medicine, Langone <strong>Health</strong><br />

Kelly Kelleher, M.D., M.P.H.<br />

Direc<strong>to</strong>r, Center for Innovation in Pediatric Practice<br />

& Vice President, Community and <strong>Health</strong> Services Research,<br />

The Research Institute at Nationwide <strong>Children’s</strong> Hospital<br />

Michael Hogan, Ph.D.<br />

Principal, Hogan <strong>Health</strong> Solutions<br />

Fall 2018


<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> Behavioral <strong>Insurance</strong> <strong>Health</strong> <strong>Policies</strong> and the <strong>to</strong> Individual <strong>Promote</strong> <strong>Health</strong> <strong>Children’s</strong> <strong>Insurance</strong> <strong>Mental</strong> Market <strong>Health</strong>


Dear Reader,<br />

Now is a time of change in health and human services policy. Many of the changes could have profound<br />

implications for behavioral health. This paper is one in a series of papers proposing solution-oriented<br />

behavioral health policies.<br />

The past decade has been a time of steady advances in behavioral health policy. For example, we have<br />

met many of the objectives related <strong>to</strong> expanding health insurance coverage for people with behavioral<br />

health conditions. Coverage is now expected <strong>to</strong> be on a par with that available <strong>to</strong> individuals with any<br />

other health conditions, although parity implementation has encountered roadblocks. Coverage of evidencebased<br />

treatments has expanded with insurance, but not all of these services are covered by traditional<br />

insurance, necessitating other sources of funding, such as from block grants.<br />

Much has improved; much remains <strong>to</strong> be accomplished.<br />

As funders, The Thomas Scattergood Behavioral <strong>Health</strong> Foundation and Peg’s Foundation believe that<br />

now more than ever philanthropic support in the area of policy is critical <strong>to</strong> improving health outcomes<br />

for all. We ask that you share this paper and the others in the series with your programmatic partners,<br />

local, state, and federal decision makers, advocacy organizations, and voters.<br />

We believe that these papers analyze important issues in behavioral health policy, can inform policymaking,<br />

and improve health outcomes. In the back of the paper, there are suggested ways of how one<br />

can use the paper <strong>to</strong> further share these solution-oriented ideas and advocate for change. We hope these<br />

papers help <strong>to</strong> extend progress and avoid losing ground at a time of change in policy.<br />

Sincerely,<br />

Joseph Pyle, M.A.<br />

President<br />

Scattergood Foundation<br />

Founding Partner of Series<br />

Rick Kellar, M.B.A.<br />

President<br />

Peg’s Foundation<br />

Founding Partner of Series<br />

Howard Goldman, M.D., P.h.D.<br />

Series Edi<strong>to</strong>r


We would like <strong>to</strong> acknowledge the following individuals for their participation in<br />

the convening and the ongoing process that led <strong>to</strong> the conceptualization of the<br />

papers in this series.<br />

Colleen Barry, Ph.D., M.P.P.<br />

Bloomberg School of Public <strong>Health</strong> at<br />

John Hopkins University<br />

Pamela Greenberg, M.P.P.<br />

Association for Behavioral <strong>Health</strong><br />

and Wellness<br />

Sandra Newman, Ph.D.<br />

John Hopkins Bloomberg School of<br />

Public <strong>Health</strong><br />

Cynthia Baum-Baicker, Ph.D.<br />

Thomas Scattergood Behavioral<br />

<strong>Health</strong> Foundation<br />

Lisa Dixon, M.D., M.P.H.<br />

Columbia University College of<br />

Physicians and Surgeons,<br />

New York State Psychiatric Institute<br />

Sara E. Dugan, Pharm.D., B.C.P.P, B.C.P.S<br />

Northeast Ohio Medical University<br />

Arthur Evans, Ph.D.<br />

American Psychological Association<br />

Alyson Ferguson, M.P.H.<br />

Thomas Scattergood Behavioral<br />

<strong>Health</strong> Foundation<br />

Richard Frank, Ph.D.<br />

Harvard Medical School<br />

Rachel Garfield, Ph.D.<br />

Kaiser Family Foundation<br />

Aaron Glickman, B.A.<br />

Perelman School of Medicine,<br />

University of Pennsylvania<br />

Howard Goldman, M.D., Ph.D.<br />

University of Maryland School of Medicine<br />

Kimberly Hoagwood, Ph.D.<br />

New York University School of Medicine<br />

Michael Hogan, Ph.D.<br />

Case Western Reserve University<br />

School of Medicine<br />

Chuck Ingoglia, M.S.W.<br />

National Council for Behavioral <strong>Health</strong><br />

Sarah Jones, M.D. Candidate<br />

Thomas Scattergood Behavioral<br />

<strong>Health</strong> Foundation<br />

Rick Kellar, M.B.A.<br />

Peg’s Foundation<br />

Jennifer Mathis, J.D.<br />

Bazelon Center for <strong>Mental</strong> <strong>Health</strong> Law<br />

Amanda Mauri, M.P.H.<br />

Thomas Scattergood Behavioral<br />

<strong>Health</strong> Foundation<br />

Brian McGregor, Ph.D.<br />

Satcher <strong>Health</strong> Leadership Institute at<br />

Morehouse School of Medicine<br />

Erik Messamore, M.D., Ph.D<br />

Northeast Ohio Medical Univerisity<br />

Mark Munetz, M.D.<br />

Northeast Ohio Medical University<br />

Joe Pyle, M.A.<br />

Thomas Scattergood Behavioral<br />

<strong>Health</strong> Foundation<br />

Lloyd Sederer, M.D.<br />

New York State Office of <strong>Mental</strong> <strong>Health</strong>,<br />

Mailman School of Public <strong>Health</strong> at<br />

Columbia University<br />

Dominic Sisti, Ph.D.<br />

Scattergood Program for Applied Ethics<br />

in Behavioral <strong>Health</strong> Care<br />

Perelman School of Medicine,<br />

University of Pennsylvania<br />

Andrew Sperling, J.D.<br />

National Alliance for <strong>Mental</strong> Illness<br />

Hyong Un, M.D.<br />

Aetna<br />

Kate Williams, J.D.<br />

Thomas Scattergood Behavioral<br />

<strong>Health</strong> Foundation<br />

Glenda Wrenn, M.D., M.S.H.P.<br />

Satcher <strong>Health</strong> Leadership Institute at<br />

Morehouse School of Medicine<br />

Julia Zur, Ph.D.<br />

Kaiser Family Foundation<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

4


Titles in the Paper Series<br />

Edi<strong>to</strong>rs Howard Goldman, M.D., Ph.D. and Constance Gartner, M.S.W.<br />

America’s Opioid Epidemic Lloyd Sederer, M.D.<br />

Behavioral <strong>Health</strong> and the Individual <strong>Health</strong> <strong>Insurance</strong> Market: Preserving Key<br />

Elements of Reform Richard Frank, Ph.D. and Sherry Glied, Ph.D., M.A.<br />

Bringing Treatment Parity <strong>to</strong> Jail Inmates with Schizophrenia Mark R. Munetz,<br />

M.D., Erik Messamore, M.D., Ph.D, and Sara E. Dugan, Pharm.D., B.C.P.P, B.C.P.S<br />

Coordinated Specialty Care for First-Episode Psychosis: An Example of Financing<br />

for Specialty Programs Lisa Dixon, M.D., M.P.H.<br />

Employing People with <strong>Mental</strong> Illness in the 21st Century: Labor Market Changes<br />

and Policy Challenges Richard Frank, Ph.D. and Sherry Glied, Ph.D., M.A.<br />

Fentanyl and the Evolving Opioid Epidemic: What Strategies Should Policymakers<br />

Consider? Colleen Barry, Ph.D., M.P.P.<br />

Improving Outcomes for People with Serious <strong>Mental</strong> Illness and Co-Occurring<br />

Substance Use Disorders in Contact with the Criminal Justice System Glenda<br />

Wrenn, M.D., M.S.H.P., Brian McGregor, Ph.D., and Mark Munetz, M.D.<br />

Medicaid’s Institutions for <strong>Mental</strong> Diseases (IMD) Exclusion Rule: A Policy Debate<br />

Jennifer Mathis, J.D., versus Dominic A. Sisti, Ph.D. and Aaron Glickman, B.A.<br />

Suicide Is a Significant <strong>Health</strong> Problem Michael Hogan, Ph.D.<br />

The Current Medicaid Policy Debate and Implications for Behavioral <strong>Health</strong>care in<br />

the United States Rachel Garfield, Ph.D., M.H.S. and Julia Zur, Ph.D.


<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

6


<strong>Redesigning</strong> <strong>Federal</strong><br />

<strong>Health</strong> <strong>Insurance</strong><br />

<strong>Policies</strong> <strong>to</strong> <strong>Promote</strong><br />

<strong>Children’s</strong> <strong>Mental</strong><br />

<strong>Health</strong><br />

Kimberly Hoagwood, Ph.D.<br />

Cathy and Stephen Graham Professor and Vice Chair for Research, New York University<br />

& Vice Chair for Research, Department of Child and Adolescent Psychiatry, NYU School of<br />

Medicine, Langone <strong>Health</strong><br />

Kelly Kelleher, M.D., M.P.H.<br />

Direc<strong>to</strong>r, Center for Innovation in Pediatric Practice & Vice President, Community and <strong>Health</strong> Services Research,<br />

The Research Institute at Nationwide <strong>Children’s</strong> Hospital<br />

Michael Hogan, Ph.D.<br />

Principal, Hogan <strong>Health</strong> Solutions


1<br />

The Problem: <strong>Policies</strong><br />

Address Deficits Rather<br />

than <strong>Promote</strong> <strong>Health</strong>y<br />

Development<br />

Effective interventions <strong>to</strong> enhance child and adolescent mental health can be focused<br />

on rehabilitation, treatment of acute conditions, prevention of new conditions,<br />

or promotion of mental well-being. Although a growing body of science suggests<br />

that the most cost-effective and moral solutions focus on early promotion and<br />

prevention, the U.S. federal agencies that spend the most on child and adolescent<br />

mental health continue <strong>to</strong> focus their payments on rehabilitative and treatment<br />

services. Specifically, the federal Medicaid and <strong>Children’s</strong> <strong>Health</strong> <strong>Insurance</strong> Program<br />

(CHIP) programs are the dominant revenue sources for behavioral health services <strong>to</strong><br />

children and adolescents in the U.S. Although there are other funding streams that<br />

cover early education and developmental services for children (e.g., Maternal and<br />

Child <strong>Health</strong> Services Block Grant [Title V, Social Security Act]; Head Start early intervention<br />

services [via the Individuals with Disabilities Education Act, Part C]); Child<br />

Care Development Block Grant; and the Maternal, Infant, and Early Childhood Home<br />

Visiting Program), Medicaid and CHIP cover almost half of all children with special<br />

healthcare needs. Medicaid and its Early Prevention, Screening, Diagnosis and Treatment<br />

Program (EPSDT) and CHIP offer health and behavioral healthcare coverage for<br />

children whose parents are unable <strong>to</strong> afford private health insurance. Although these<br />

programs are designed nationally, they are administered at the state level.<br />

Medicaid alone covers a <strong>to</strong>tal of 70 million individuals, including a large share of vulnerable<br />

populations—32% of children (44.2 million) and 46% of pregnant women—and<br />

has an annual cost of $475 billion <strong>to</strong> federal and state taxpayers. 1 However, because<br />

Medicaid’s EPSDT and CHIP emerged from adult-oriented insurance models, they are<br />

primarily oriented <strong>to</strong>ward providing services when problems arise, rather than supporting<br />

the conditions for children’s healthy development. Access <strong>to</strong> most services<br />

under Medicaid requires that a licensed provider, in an approved or licensed site,<br />

assign a diagnosis for an illness <strong>to</strong> an individual—meaning that <strong>to</strong> access behavioral<br />

health services, a mental health problem has <strong>to</strong> have already developed.<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

8


Children, however, are not small adults. Neurodevelopmental studies, animal models,<br />

and studies of brain plasticity in infancy have established how important early<br />

childhood is for forming capacities for lifelong development, 2,3,4 marking this as a<br />

period of both great vulnerability and great opportunity. 5 The neural connections<br />

that form the building blocks of brain development begin before birth and continue<br />

in<strong>to</strong> early adulthood. Therefore, early interventions can have profound and long-lasting<br />

effects, and a wide range of interventions addressing neuro-regulation and social<br />

relationships are effective. 6,7,8 Just under half of U.S. children experience at least<br />

one adverse childhood event (ACE), and one in ten experiences three or more; these<br />

negative events place them at high risk for later negative health and mental health<br />

outcomes. Although a strong body of evidence traces the impact of ACEs on lifelong<br />

development, 9,10,11 an equally strong body of evidence exists about effective prevention<br />

and early intervention services <strong>to</strong> mitigate these negative outcomes. 12<br />

Therefore, the opportunity is <strong>to</strong> redesign Medicaid, EPSDT, and CHIP so that they<br />

optimize children’s development and functioning and promote the capacity for<br />

lifelong health and quality of life. We recognize that the changes we suggest will not<br />

affect all U.S. children, because these policies cover only a portion of the nation’s<br />

child population—those in families with lower incomes. Nevertheless, making these<br />

changes would set a precedent. We also recognize that decisions about modifications<br />

are made at both federal and state levels and that there is considerable latitude<br />

for states <strong>to</strong> adjust coverage. In this paper, we focus primarily on policy levers<br />

where federal guidance <strong>to</strong> states will promote coverage likely <strong>to</strong> optimize children’s<br />

healthy development. A thoughtful redesign will attend <strong>to</strong> the unique developmental<br />

issues of children, including the systems in which they live, learn, and seek services<br />

(i.e., home, school, neighborhood, and primary healthcare). We argue for a redesign<br />

<strong>to</strong> explicitly address four issues with greater relevance <strong>to</strong> children’s development:<br />

periodicity (i.e., the developmental continuum, requiring ongoing assessment of<br />

functioning); provider capacity (requiring expansion of service providers <strong>to</strong> include<br />

skilled nonprofessional providers and increased training); place or setting expansion<br />

<strong>to</strong> offer continuous, coordinated, responsive, and flexible coverage across a range of<br />

locations; and payment reform <strong>to</strong> ensure that services are adequately reimbursed in<br />

different contexts and <strong>to</strong> promote investments in prevention and early intervention<br />

programming. We conclude with specific recommendations.


2<br />

The Need for Policy<br />

Redesign: Four Key<br />

Areas<br />

Periodicity<br />

An orienting feature that distinguishes children from adults is their developmental<br />

plasticity. To promote and optimize children’s functioning, ongoing assessment and<br />

moni<strong>to</strong>ring of core functional markers is needed <strong>to</strong> guide the rapid deployment of interventions—as<br />

conditions develop—for children with high-risk profiles (e.g., three or<br />

more ACEs). Therefore, measurement and moni<strong>to</strong>ring of children’s functioning over<br />

time must be frequent (periodic) and coordinated across systems and must take in<strong>to</strong><br />

account developmental change, proxy reports, and temporal stability of measures as<br />

complicating fac<strong>to</strong>rs in measurement psychometrics.<br />

What Is Missing?<br />

The current design of Medicaid’s EPSDT and CHIP falls short. The Center for Medicaid<br />

and Medicaid Services (CMS) 2013 policy guidance 13 on the assessment of childhood<br />

functioning recommends using the periodicity schedules set by Bright Futures<br />

and standardized assessments (e.g., Ages and Stages Questionnaire and Pediatric<br />

Symp<strong>to</strong>ms Checklist) in general medical settings for children. These are necessary<br />

but insufficient steps. These nonspecific recommendations are implemented poorly<br />

in most settings. First, state EPSDT programs have noted consistent shortcomings in<br />

the actual delivery of developmental and behavioral screening and treatment in primary<br />

care and general medical settings. Second, Medicaid and CHIP reimbursement<br />

policies exclude payment for behavioral health services provided in numerous other<br />

settings that are not licensed or certified as specialty sites, where high-risk children<br />

are often found, such as homes, general classrooms, juvenile justice settings, foster<br />

care homes, and youth development programs. Third, current measurement standards<br />

are not tied <strong>to</strong> key child functioning goals, such as kindergarten readiness,<br />

third-grade literacy, or high school graduation. This is because pediatric measures<br />

for state reporting are focused narrowly on follow-up after hospitalization or diagnosis-specific<br />

services (e.g., for ADHD), not on functioning. The implication for providers<br />

and payers: that the process of developmental and behavioral screening is more<br />

important than outcome.<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

10


Provider Capacity<br />

There are substantial workforce shortages and a likely misallocation of providers<br />

who care for children’s behavioral health. This includes shortages of pediatricians,<br />

case managers, special education teachers, social workers, psychiatrists, and behavioral<br />

healthcare workers, particularly in rural areas. 14,15,16,17,18 Coupled with these<br />

workforce shortages are issues around lack of training—especially in developmental<br />

assessment and psychosocial interventions—for general healthcare providers,<br />

teachers, and other frontline professionals who work with children. Training deficits<br />

are most pronounced in knowledge about basic developmental competencies,<br />

recognition of behavioral health issues, and evidence about effective early interventions.<br />

19,20 There are <strong>to</strong>o few specialists, and the generalists do not understand the<br />

emerging science on mental health promotion, prevention, and early intervention<br />

that could alter the trajec<strong>to</strong>ry of many children.<br />

What Is Missing?<br />

Policy guidance is absent <strong>to</strong> support widespread workforce training on the use of<br />

effective prevention and early intervention programs. Also absent is guidance promoting<br />

expansion of the behavioral health workforce <strong>to</strong> include family peer support,<br />

youth peer support, and telemedicine. These are low-cost, acceptable, and effective<br />

alternative services. Medicaid guidance on funding sources for family and youth<br />

peer support services and telemental health for children is inconsistent and poorly<br />

unders<strong>to</strong>od or applied. The most recent federal guidance on peer support 21 provides<br />

only general guidelines on scope of and access <strong>to</strong> peer support services. Some states<br />

are using Medicaid administrative matches <strong>to</strong> pay for these services. Similarly,<br />

federal guidance continues <strong>to</strong> support low reimbursement rates for telemedicine,<br />

compared with reimbursement for face-<strong>to</strong>-face services.


Place<br />

Promoting children’s behavioral health and resilience is most effective when<br />

services can be provided in places where young children develop that include<br />

nontraditional healthcare settings, such as homes, schools, and other natural<br />

contexts (e.g., childcare settings and faith-based settings). This is because many<br />

effective interventions focus on improving skills of parents and other primary<br />

caregivers (e.g., early education staff). It also means that providers (i.e., case<br />

managers, early learning specialists, and healthcare specialists) need <strong>to</strong> be trained<br />

in how <strong>to</strong> provide services within these nontraditional settings. However, both<br />

Medicaid’s EPSDT and CHIP favor delivery of services in more traditional settings<br />

(i.e., outpatient and hospital-based settings).<br />

What Is Missing?<br />

The provision of services in nontraditional mental health service settings, such<br />

as in the home and in childcare settings, is covered under Medicaid’s Home and<br />

Community-Based Services Waiver program, which also includes the provision of<br />

intensive in-home services, but these services are largely case management for<br />

already identified “patients,” and coverage in schools is limited. The covered services<br />

do not currently include prevention or promotion services.<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

12


Payment<br />

Paying for children’s prevention and health promotion services requires thinking differently about<br />

return on investment, the balance of long-term savings vs. short term gains, and the availability of<br />

appropriate codes with which <strong>to</strong> support these services (i.e., nonmedical necessity).<br />

What Is Missing?<br />

There is no code enabling reimbursement for moni<strong>to</strong>ring or tracking of pediatric referrals <strong>to</strong><br />

behavioral health services, thus making it unlikely that follow-through will be tracked and measured<br />

and that children will receive follow-up care. In addition, the current design incentivizes shortterm<br />

contracts with managed care organizations, thus making long-term investments, which<br />

could include prevention and early intervention programs, difficult <strong>to</strong> secure. The payment models<br />

that exist are largely based on fee-for-service configurations. To address children’s developmental<br />

functioning, however, and <strong>to</strong> ensure that no child is missed, population-based payments linked<br />

<strong>to</strong> full accountability need <strong>to</strong> be integrated in<strong>to</strong> policies. This could include pediatric accountable<br />

care organizations (ACOs) and value-based purchasing mechanisms, discussed below in<br />

recommendations.<br />

There is no code enabling reimbursement for moni<strong>to</strong>ring or<br />

tracking of pediatric referrals <strong>to</strong> behavioral health services,<br />

thus making it unlikely that follow-through will be tracked<br />

and measured and that children will receive follow-up care.


3<br />

Action Items for<br />

Policymakers and<br />

Advocates<br />

1. Develop and Implement Measures That Assess<br />

<strong>Children’s</strong> Development (Periodicity)<br />

An important step is <strong>to</strong> develop measures that allow for frequent moni<strong>to</strong>ring of<br />

children’s development and functioning—measures that capture childhood’s incremental<br />

changes, with explicit attention <strong>to</strong> modifiable community and neighborhood<br />

fac<strong>to</strong>rs 22,23,24 that have an impact on children’s health and development. Although<br />

CMS’s 2016 overhaul of Medicaid managed care 25 requires states <strong>to</strong> collect a standard<br />

set of encounter data, these data do not include periodic measurement of children’s<br />

development. States are required <strong>to</strong> report on <strong>Health</strong>care Effectiveness Data and<br />

Information Set (HEDIS) measures, but measures for children are focused largely on<br />

hospitalization rates or on specific diagnoses (e.g., ADHD and depression). The National<br />

Academy of Science, Engineering, and Medicine (NASEM) recommends an alternative<br />

approach: the Vital Signs: Core Metrics for <strong>Health</strong> and <strong>Health</strong> Care Progress<br />

report identifies 15 domains for capturing a range of health outcomes; however, most<br />

of these domains are focused on adults, not children. 26 A recent initiative, organized<br />

by NASEM’s Forum on Promoting <strong>Children’s</strong> Cognitive, Affective, and Behavioral<br />

<strong>Health</strong>, is identifying developmentally responsive functional measures for children<br />

<strong>to</strong> parallel or complement the broader Vital Signs work. The pediatric measures will<br />

capture cross-system issues, especially important for children; account for continuity<br />

of care and social determinants of health that comprise children’s environments;<br />

and include community and neighborhood measures. 22,23,27<br />

2. Expand the Range of Providers Whose Services<br />

Are Reimbursable<br />

There are limited payment options under current mainstream federal policies for services<br />

delivered by professionals other than licensed medical or health providers. <strong>Federal</strong><br />

guidance is needed <strong>to</strong> clarify the competencies—not professional degrees—needed<br />

by a wide range of professionals (e.g., early childhood paraprofessionals and parent<br />

and youth peer support providers) who have the potential <strong>to</strong> provide evidence-based,<br />

appropriate early intervention and prevention services. For example, only about a<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

14


third of states currently use Medicaid funding for peer parent support services, 28<br />

although evidence for these programs, as well as a national certification process<br />

and pool of certified candidates, exists. And, although 34 states report that Medicaid<br />

covers an “early childhood mental health specialist,” no state covers services that<br />

aim <strong>to</strong> benefit an entire classroom or group of children through consultation or group<br />

training activities. Opportunities also exist <strong>to</strong> expand provider capacity by increasing<br />

federal reimbursement for telemedicine behavioral health coverage and for states <strong>to</strong><br />

expand their coverage of this service, which reaches rural areas where such services<br />

are critically needed; currently, the Medicaid telemedicine provider reimbursement<br />

rates are far below both Medicare and commercial insurance rates. 29<br />

Recent federal efforts <strong>to</strong> increase workforce capacity via evidence-based training<br />

and technical assistance do not cover early childhood prevention and intervention<br />

programming or providers. They need <strong>to</strong> do so. The Substance Abuse and <strong>Mental</strong><br />

<strong>Health</strong> Services Administration’s recent program announcements for regional <strong>Mental</strong><br />

<strong>Health</strong> Technology Transfer Centers 30 and Prevention <strong>Mental</strong> <strong>Health</strong> Technology<br />

Transfer Centers 31 represent a significant development. However, the announcements<br />

focus on “those with serious mental illness” and “provide training and technical<br />

assistance services <strong>to</strong> the substance abuse prevention field.” Neither of these<br />

efforts is likely <strong>to</strong> provide training and technical assistance <strong>to</strong> help establish early<br />

intervention programming needed for children and parents <strong>to</strong> remediate the effect<br />

of ACEs and prevent mental illnesses from developing. This is a missed opportunity.<br />

Some states are enacting statewide training initiatives <strong>to</strong> re<strong>to</strong>ol their current workforce,<br />

including New York State’s Evidence-Based Treatment and Dissemination<br />

Center and Minnesota’s Evidence-Based Practices initiative, both of which utilize<br />

the Managing and Adapting Practice system. 32 States are also addressing workforce<br />

shortages by creating credentialing processes <strong>to</strong> train and certify peer support<br />

providers, including parents and youth. 33,34,35,36,37 Family peer advocates (FPAs) are a<br />

group of providers whose work improves family engagement, access, and knowledge<br />

about quality. 38,39,40,41,42,43,44 A national training and certification program also exists<br />

for peer parent support providers in children’s mental health. 45 New York State has<br />

made a significant investment in family peer support, training and certifying nearly<br />

800 FPAs, and is expanding its training and certification efforts by using different<br />

models (e.g., train-the-trainer), 46 including launching online training modules, 47 in<br />

anticipation of the growing use of FPAs now that Medicaid reimburses for those<br />

services. <strong>Federal</strong> guidance is needed <strong>to</strong> help states expand reimbursable services by<br />

using nontraditional workforces, including family and youth peer support specialists.<br />

Telemedicine and digital services also counteract the effects of workforce shortages.


3. <strong>Promote</strong> “Place-Based” Services <strong>to</strong> Serve Children<br />

and Parents Where They Are<br />

Coverage of services needs <strong>to</strong> be expanded <strong>to</strong> include services delivered where<br />

children spend most of their time (e.g., homes, schools, and communities). This<br />

should include support for evidence-based parenting programs, early intervention<br />

skills training, and school readiness (e.g., early literacy and reading). These kinds of<br />

services do not fit within the traditional model because they are delivered outside<br />

of specialty mental health clinics and do no necessitate a mental health diagnosis.<br />

NASEM’s recently formed Collaborative on <strong>Health</strong>y Parenting in Primary Care has<br />

identified specific policy opportunities for delivering evidence-based parent support<br />

programs and family-focused interventions (e.g., Triple P and Incredible Years) in<br />

primary care, 48 but these are not reimbursable under Medicaid or CHIP. In addition,<br />

the U.S. Preventive Services Task Force recently recommended both public and private<br />

insurance coverage for family-focused interventions as a preventive measure.<br />

Embedding reimbursement codes for these kinds of services would facilitate children’s<br />

healthy development. Current Medicaid regulations do not overtly promote<br />

parent enrollment in evidence-based parent training programs; only 12 states report<br />

that Medicaid pays for parenting programs (and only two of these states, Michigan<br />

and Oregon, require providers <strong>to</strong> use an evidenced-based parenting program); 37<br />

states (76%) report that they do not cover these services, 49 despite evidence of their<br />

effectiveness 6,50,51 as well as their significant cost-benefit savings. 52 Finally, current<br />

Medicaid policy design sometimes promotes discontinuous coverage and disruption<br />

of services for many of the highest-risk children when there are minor changes in<br />

residence, foster care transitions, and eligibility changes due <strong>to</strong> disability.<br />

Another potential avenue for expanding place-based coverage is through the Home<br />

and Community-Based Services (HCBS) Waiver program, authorized by the Social<br />

Security Act. This program allows for the provision of standard medical and nonmedical<br />

services in the home or community. The target of HCBS services is individuals<br />

with established diagnoses and usually those who already have tangible<br />

impairments. As such, this “flexible” model is not able <strong>to</strong> provide developmental<br />

interventions for children who are high risk of not flourishing (i.e., who have multiple<br />

ACEs), because these children are not yet diagnosed or disabled. HCBS services<br />

have begun <strong>to</strong> revolutionize care for children with autism spectrum disorders, with<br />

covered behavioral interventions aimed at improving functioning. Such an approach<br />

would be very useful for children who have experienced multiple ACEs. This would<br />

require redefining eligibility, perhaps by limiting access <strong>to</strong> children with high ACE<br />

scores (e.g., three or more), linking the services <strong>to</strong> full-service pediatric practices,<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

16


and defining the scope of intervention (e.g., number and type of sessions). <strong>Federal</strong><br />

guidance could consider piloting, via a limited waiver opportunity paired with a robust<br />

evaluation, HCBS services coordinated by full-service pediatric practices (using<br />

collaborative care bundled payments) for young children at high risk of developing a<br />

behavioral health diagnosis. The services should be focused on evidence-based interventions<br />

and circumscribed as appropriate in terms of amount, scope, and duration.<br />

4. Further Develop Innovative Payment Models and Tools <strong>to</strong><br />

<strong>Promote</strong> Prevention and Early Intervention Programs<br />

More sophisticated, complex, creative, and sustainable financing mechanisms are<br />

needed <strong>to</strong> fund early prevention and intervention programming. Some states are<br />

finding innovative ways, in the absence of federal guidance, <strong>to</strong> invest in the early<br />

years. Oregon’s “At-Risk Codes” allow payments for early intervention <strong>to</strong> reduce the<br />

development of serious mental health conditions later, 53 and New York State’s “First<br />

1,000 Days of Medicaid” recognizes that a child’s first three years are the most crucial<br />

years of development. 54<br />

New Payment Models<br />

Several CMS efforts have attempted <strong>to</strong> address the development of new payment<br />

models, including CMS’s 2017 Request for Information on Pediatric Alternative<br />

Payment Model Opportunities, 55 which sought input on the design of alternative<br />

payment models <strong>to</strong> improve the health of children and youth covered by Medicaid<br />

and CHIP and focused on concepts that encourage pediatric providers <strong>to</strong> collaborate<br />

with health-related social service providers at the state and local levels. However, no<br />

further follow-up or request for proposals (RFP) has been issued (as of July 2018). CMS<br />

also funded 31 demonstration projects under the Accountable <strong>Health</strong> Communities<br />

Model and developed a <strong>Health</strong>-Related Social Needs Screening Tool. 56 Opportunities<br />

exist <strong>to</strong> provide additional technical assistance <strong>to</strong> communities <strong>to</strong> further develop<br />

these needed models, with a focus on pediatric ACOs and expanding value-based purchasing<br />

mechanisms <strong>to</strong> include pediatric health and behavioral health. To date (July<br />

2018), no RFPs or further federal policy regulations or policy guidance exist <strong>to</strong> support<br />

broader implementation of these alternative financing models/mechanisms.


Pediatric ACOs<br />

Pediatric ACOs began nearly two decades ago. However, utilization of this model is<br />

not widespread and is exclusively affiliated with large hospital systems. As such,<br />

the variability across models—due <strong>to</strong> state-<strong>to</strong>-state differences in Medicaid and lack<br />

of federal guidance on structure and financing—has made existing pediatric ACO<br />

models nationwide difficult <strong>to</strong> compare, align, or regulate for best practices. 57 Two<br />

recent evaluations of pediatric ACOs, one of early adopters and another profiling<br />

hospital-based models, found a need for more complex financial models <strong>to</strong> account<br />

for the long-term investment and short-term savings. Further, the cost-savings<br />

goals tend <strong>to</strong> take precedence over measurement of quality, and there is a need for<br />

development of ACO quality measures. 57,58<br />

One example of a pediatric ACO model is Nationwide <strong>Children’s</strong> Hospital Partners<br />

for Kids (PFK), one of the oldest pediatric ACOs (founded in 1994) and a full-risk,<br />

population-based model that receives a Medicaid per-member per-month age- and<br />

sex-adjusted payment. PFK has demonstrated lower costs than fee-for-service or<br />

managed care organizations. Importantly, this slowing in cost growth was achieved<br />

without losses in overall quality or outcomes of care. 59 In addition, PFK’s care<br />

coordination reduced inpatient and emergency department utilization. 60<br />

Value-based purchasing<br />

In the past decade, many states have undertaken significant efforts <strong>to</strong> overhaul<br />

their Medicaid plans, 61,62 with reforms aimed at moving away from fee-for-service<br />

<strong>to</strong>ward increasing the value of the care they are providing. However, these efforts<br />

are happening in the absence of federal guidance, leading <strong>to</strong> uncertainty and<br />

inefficiencies. These include integrating primary and behavioral healthcare<br />

and replacing fee-for-service payments with reimbursements based on clients’<br />

attainment of health outcomes. 63,64 Two-thirds of children and youth covered by<br />

Medicaid and CHIP are now in managed care. 65<br />

Examples of state innovations include Oregon, which has created coordinated care<br />

organizations that are locally governed <strong>to</strong> address community needs on a single<br />

global budget, and New York State, which is implementing the Delivery System<br />

Reform Incentive Payment program and Performing Provider Systems <strong>to</strong> restructure<br />

Medicaid <strong>to</strong> reduce avoidable hospital use by 25% over five years. However, few<br />

children are hospitalized, and this focus in New York effectively excludes pediatric<br />

services. 66 Minnesota is piloting Certified Community Behavioral <strong>Health</strong> Centers and<br />

<strong>Health</strong> Home initiatives <strong>to</strong> coordinate care across settings and providers. 67 These<br />

state innovations are using more complex financial models <strong>to</strong> try <strong>to</strong> provide more<br />

flexible services, but they are not primarily targeted at children or at promoting<br />

children’s healthy development. This needs <strong>to</strong> change.<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

18


Return on Investment <strong>to</strong>ols<br />

States would also benefit from the development of <strong>to</strong>ols that allow them <strong>to</strong> calculate<br />

their return on investment (ROI) in early prevention and intervention programming.<br />

A recently published Commonwealth Fund “return-on-investment calcula<strong>to</strong>r”<br />

(Assessing Risks and Rewards of Integrating Social Services with <strong>Health</strong> Care)<br />

enables policymakers <strong>to</strong> weigh the value of partnerships/investments in social<br />

services that are likely <strong>to</strong> improve medical outcomes. 68 An adaptation of this <strong>to</strong>ol<br />

for investments in early prevention and intervention programming for children<br />

could provide state policymakers with data regarding their investments in these<br />

prevention and early intervention programs. An important caveat, however, is<br />

that it is unethical <strong>to</strong> hinge treatment on purely financial calculations. ROI <strong>to</strong>ols<br />

for prevention are not required for other health conditions (e.g., cancer and heart<br />

disease). Nevertheless, it would be useful for planning purposes <strong>to</strong> know probable<br />

ROIs for prevention programs for children. ROI analyses can be a useful <strong>to</strong>ol <strong>to</strong><br />

encourage expanded coverage by states. For example, since the late 1990s, the<br />

Washing<strong>to</strong>n State legislature has directed the Washing<strong>to</strong>n State Institute for<br />

Public Policy (WSIPP) <strong>to</strong> calculate the ROI <strong>to</strong> taxpayers from a variety of education,<br />

prevention, and intervention programs and policies. Today, WSIPP provides ROI data<br />

for an extensive range of programs and policies <strong>to</strong> guide decision making at the<br />

state level. 52


4 Conclusions<br />

Mainstream federal policies that address children’s health needs—Medicaid, including<br />

EPSDT, and CHIP—are not designed <strong>to</strong> promote healthy development or <strong>to</strong><br />

address the unique needs of children. We call for a redesign of these programs <strong>to</strong><br />

include development of billing codes and payment options <strong>to</strong> enable frequent moni<strong>to</strong>ring<br />

of children’s development (periodicity); training, technical assistance, and<br />

coverage of a range of credentialed, nontraditional providers; expansion of covered<br />

settings; and adoption of payment models at a systems level <strong>to</strong> create a sustainable<br />

structure. Supporting children necessitates equal attention <strong>to</strong> supporting—even<br />

nurturing—their families and communities <strong>to</strong> create the conditions for positive development<br />

and life-long functioning. <strong>Federal</strong> health policy must keep pace with the<br />

scientific evidence on what is known <strong>to</strong> create the conditions for future generations<br />

of children <strong>to</strong> thrive.<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

20


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<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong>


How <strong>to</strong> use this paper <strong>to</strong><br />

“Think Bigger” and “Do Good”<br />

1 Send the paper <strong>to</strong> your local, state, and federal<br />

policy- and decision-makers<br />

2 Share the paper with mental health and substance use<br />

advocates and providers<br />

The Scattergood Foundation believes major disruption is needed<br />

<strong>to</strong> build a stronger, more effective, compassionate, and inclusive<br />

health care system — one that improves well-being and quality of<br />

life as much as it treats illness and disease. At the Foundation, we<br />

THINK, DO, and SUPPORT in order <strong>to</strong> establish a new paradigm for<br />

behavioral health, which values the unique spark and basic dignity in<br />

every human.<br />

www.scattergoodfoundation.org<br />

3 Endorse the paper on social media outlets<br />

4 Link <strong>to</strong> the paper on your organization’s website or blog<br />

5 Use the paper in group or classroom presentations<br />

6 <strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong><br />

<strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong> .” Scattergood Foundation,<br />

Philadelphia, PA (Fall 2018) www.thinkbiggerdogood.org<br />

Peg’s Foundation believes in relevant and innovative, and at times<br />

disruptive ideas <strong>to</strong> improve access <strong>to</strong> care and treatment for the<br />

seriously mentally ill. We strive <strong>to</strong> promote the implementation of a<br />

stronger, more effective, compassionate, and inclusive health care<br />

system for all. Our Founder, Peg Morgan, guided us <strong>to</strong> “Think Bigger”,<br />

and <strong>to</strong> understand recovery from mental illness is the expectation, and<br />

mental wellness is integral <strong>to</strong> a healthy life.<br />

www.pegsfoundation.org<br />

As strictly nonpartisan organizations, we do not grant permission for reprints,<br />

links, citations, or other uses of our data, analysis, or papers in any way that<br />

implies the Scattergood Foundation or Peg’s Foundation endorse a candidate,<br />

party, product, or business.<br />

F O U N D A T I O N<br />

<strong>Redesigning</strong> <strong>Federal</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Policies</strong> <strong>to</strong> <strong>Promote</strong> <strong>Children’s</strong> <strong>Mental</strong> <strong>Health</strong><br />

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